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Law Offices of Snider & Assoc., LLC v. Gates, No. 10-1822, 2014 WL 2200683 (D.D.C. May 28, 2014) (Cooper, J)

Date

Law Offices of Snider & Assoc., LLC v. Gates, No. 10-1822, 2014 WL 2200683 (D.D.C. May 28, 2014) (Cooper, J)

Re: Request for payroll records of civilian employees of Norfolk Naval Shipyard

Disposition: Granting defendant's motion for summary judgment

  • Litigation Considerations, Adequacy of Search:  The court holds that "[the Defense Finance and Accounting Service Agency's ('DFAS')] affidavits are specific enough to enable the Court to determine that an adequate search was performed."  The court finds that "[defendant's] declarations that only DCPS is likely to contain responsive records and that it requires social security numbers—coupled with his position within DFAS and his explanation that DCPS is the only record system likely to contain Department of the Navy civilian employee records—are sufficient to establish that DFAS conducted an adequate search."  Moreover, the court finds that the requester’s "purported receipt of similar information from other entities without providing social security numbers fails to establish that DFAS does not require social security numbers to search its database because these other entities are all distinct organizations with distinct record systems."
     
  • Litigation Considerations, Discovery:  The court holds that "[b]ecause DFAS has demonstrated that it performed an adequate search and [plaintiff] has not overcome the presumption of good faith, the Court denies [plaintiff's] request for discovery."
Court Decision Topic(s)
District Court opinions
Litigation Considerations, Adequacy of Search
Litigation Considerations, Discovery
Updated February 3, 2022